Defense Export Compliance: 7 Grounds for Refusal and Suspension (2026 Update)

Customs and legal analysts have identified a critical shift in the Ukrainian defense export landscape: the implementation of Resolution No. 875. This regulation does more than streamline procedures—it formalizes a dual-track system that balances the need for international defense cooperation (the 'Drone Deal' format) with rigorous state control mechanisms.

The Regulatory Authorization Framework

• 7 specific grounds for export permit refusal, ranging from non-compliance with buyer screening to prioritizing domestic Defense Force needs.
• 3 scenarios for suspending an active license, including failure to fulfill internal state defense contracts.
• A mandatory valuation methodology for finished goods (minimum UAH 15 million threshold) to prevent under-invoicing and ensure proper contributions to the special fund.
• A 'Fast-Track' timeline for partner states, aiming for permit issuance within 30 days, provided the transaction meets specific security and end-use criteria.

Strategic Implications for Contract Planning

Each ground for refusal serves as a compliance checkpoint that must be mitigated prior to submission. Furthermore, the mandatory valuation methodology directly impacts deal economics: artificial pricing in a contract will not reduce mandatory contributions but will trigger immediate regulatory scrutiny. Exporters must now also account for the 'Critical Goods' list, updated quarterly by the Ministry of Defence, which can route even standard applications to the Interagency Commission for review.

A formal refusal is more than lost time; it is a signal within the export control system that complicates future applications. It is more cost-effective to prevent a denial than to appeal one.

Pre-Submission Case Assessment

Global Miltech Legal conducts a comprehensive pre-audit of export cases against all seven grounds for refusal, verifies valuations under the new state methodology, and prepares document packages designed for first-time approval. We encourage you to contact us prior to filing your application; a preliminary review of your 'Drone Deal' eligibility and critical goods status can save months of administrative delay.